APRA supports retention of FTC Rebuilt/Remanufactured Parts Guide

The Automotive Parts Remanufacturers Association (APRA) recently filed extensive comments supporting retention of the Federal Trade Commission's Guides for the Rebuilt, Reconditioned and Other Used Automobile Parts. These Guides were adopted by the FTC prior to 1979 and have been periodically reviewed and updated since. The Guides establish minimum restoration requirements which must be met before a used part can be labeled "rebuilt" or "remanufactured". They also prescribe labeling requirements for the rebuilt/remanufactured parts so that they will not be confused with new parts.

APRA has been a long time supporter of the Guides and has promoted them among its members and the remanufacturing industry in general. "The FTC Guides provide remanufacturers with an excellent description of the procedures necessary to process their cores into remanufactured parts and the proper methods to label, market and sell them," said APRA President, William Gager. "Without the Guides, those parts suppliers who merely clean or superficially repair used vehicle parts would be more likely to misrepresent the condition of their parts and to market them as comparable to remanufactured/rebuilt parts or even new parts."

The Guides require full disclosure of whether a non-new motor vehicle part is "used," "secondhand," repaired," "remanufactured," "reconditioned," "rebuilt" or "relined." They also require that before a part can be labeled "remanufactured" or "rebuilt" that it be "dismantled and reconstructed as necessary, all of its internal and external parts cleaned and made free from rust and corrosion, all impaired, defective or substantially worn parts restored to a sound condition or replaced with new, rebuilt or unimpaired used parts, all missing parts replaced with new, rebuilt or unimpaired used parts and such rewinding, machining and other operations performed as are necessary to put the industry product in sound working condition."

Finally, the Guides require the remanufacturer/rebuilder disclose on the part, packaging and in advertising and marketing materials that the part has been remanufactured/rebuilt and to some extent the identity of the remanufacturer/rebuilder.

The FTC has requested comments on whether the Guides should be retained; their current effect on consumers and small businesses and whether any changes to the Guides were necessary. APRA strongly urged the FTC to retain the Guides. The Association believes that compliance with the Guides is not difficult and normally not costly either to the parts supplier or the consumer. The benefits for the consumer as well as the service technician from the full disclosure required by the Guides far outweigh any small cost. APRA also suggested that the Guides be modified to make it clear that they applied to imported parts as well as domestic parts; to have them apply to all farm, construction and industrial vehicles; to make the requirements for clear and conspicuous disclosure more precise; to add language requiring a parts supplier to distinguish those parts which are repaired and reconditioned (but not rebuilt or remanufactured) from those which are being sold in used "as-is" condition and to require that the original trademark be left on the rebuilt/remanufactured part.